Save Centennial Valley Association v. McGruder

CourtSouth Dakota Supreme Court
DecidedMay 6, 2026
Docket31091
StatusPublished

This text of Save Centennial Valley Association v. McGruder (Save Centennial Valley Association v. McGruder) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Save Centennial Valley Association v. McGruder, (S.D. 2026).

Opinion

#31091-a-SRJ 2026 S.D. 26

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

SAVE CENTENNIAL VALLEY ASSOCIATION, INC. and CHARLES BROWN, Petitioners and Appellants,

v.

BRENDA MCGRUDER, in her capacity as Lawrence County Auditor; COUNTY OF LAWRENCE, SOUTH DAKOTA; BOARD OF COMMISSIONERS OF LAWRENCE COUNTY, SOUTH DAKOTA; RICHARD SLEEP; RICK TYSDAL; BRANDON FLANAGAN; BOB EWING; and ERIC JENNINGS, in their official capacity, Respondents and Appellees.

APPEAL FROM THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT LAWRENCE COUNTY, SOUTH DAKOTA

THE HONORABLE ERIC J. STRAWN Judge

MATTHEW J. LUCKLUM of Bangs, McCullen, Butler, Foye & Simmons, LLP Rapid City, South Dakota Attorneys for petitioners and appellants.

KATELYN A. COOK RICHARD M. WILLIAMS of Gunderson, Palmer, Nelson & Ashmore, LLP Rapid City, South Dakota Attorneys for respondents and appellees.

ARGUED MARCH 19, 2026 OPINION FILED 05/06/26 Table of Contents

JENSEN, Chief Justice ................................................................................................. 1 Factual and Procedural History ................................................................................ 1 Standard of Review .................................................................................................... 3 Analysis ...................................................................................................................... 4 #31091

JENSEN, Chief Justice

[¶1.] The Lawrence County Commission (the Commission) adopted

Ordinance #24-05, amending portions of the Lawrence County Zoning Ordinance

(Zoning Ordinance). In response, Save Centennial Valley Association (SCVA) filed a

petition with the Lawrence County Auditor (the Auditor) asserting the amendments

were a legislative decision subject to a public referendum vote pursuant to SDCL 7-

18A-15.1. The Auditor rejected the petition, informing SCVA that Ordinance #24-

05 was administrative in nature and not subject to a public referendum under the

statute. SCVA sought a writ of mandamus to force the referendum, which the

circuit court denied. SCVA appeals. We affirm.

Factual and Procedural History

[¶2.] The Commission voted to adopt Ordinance #24-05 on November 26,

2024. The Ordinance amended the conditional use permits (CUP) chapter of the

Zoning Ordinance by striking the words “County Commission” for “Board of

Adjustment” and “Planning and Zoning Board” for “Board of Adjustment.”1 SCVA

presented the Auditor with a petition to subject Ordinance #24-05 to a referendum.

There is no dispute the petition contained the required number of signatures from

qualified electors under SDCL 7-18A-18.1. However, the Auditor sought guidance

from the Commission as to whether the amendment to the Ordinance could be

certified for placement on the ballot.

1. Ordinance #24-05 made similar changes to the variance chapter of the Zoning Ordinance. SCVA makes a passing reference in its brief that “the Ordinance Amendment also made discretionary changes to items like variances,” but does not develop any arguments to suggest these changes were legislative within the meaning of SDCL 7-18A-15.1.

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[¶3.] The Commission, acting on advice of counsel, determined that

Ordinance #24-05 was “initiated to bring the existing ordinance into compliance

with state law—thereby implementing a plan already put in place by the State

Legislature[.]” In the Commission’s view, Ordinance #24-05 was not a legislative

decision, but an administrative decision, and thus not referrable. Thereafter, the

Auditor informed the petitioners in writing that Ordinance #24-05 “was an

administrative decision as defined by SDCL 7-18A-15.1 and not subject to the

referendum process.”

[¶4.] SCVA filed a petition in the circuit court seeking a writ of mandamus

against the Auditor, Lawrence County, the Commission, and each commissioner in

their official capacity (collectively, the County), directing the County to refer

Ordinance #24-05 for a public referendum vote. The County moved for judgment on

the pleadings pursuant to SDCL 15-6-12(c). The parties submitted briefs and

presented arguments at a hearing on the motion.

[¶5.] The County argued that SCVA was not entitled to mandamus relief

because Ordinance #24-05 made an administrative change designed to conform the

Zoning Ordinance to South Dakota law by providing for the board of adjustment to

consider all CUP applications. The County further argued that Ordinance #24-05

did not create any new rules or policy, but rather implemented a plan already put in

place by the Legislature and the Zoning Ordinance. Additionally, the County

argued that Ordinance #24-05 had no impact on citizen referendums because

decisions on CUPs—whether made by the Commission or the board of adjustment—

are not subject to referendum, as a petition for writ of certiorari is the sole remedy

-2- #31091

to challenge a CUP. SCVA maintained that Ordinance #24-05 was a legislative

decision because the Commission has absolute discretion under state law to decide

whether to substitute the board of adjustment for the Commission to consider CUP

applications. By making this change, SCVA asserted, Ordinance #24-05 eliminated

the ability of citizens to challenge all future CUP decisions by referendum.

[¶6.] The circuit court granted the County’s motion for judgment on the

pleadings, determining that SCVA was not entitled to a writ of mandamus because

Ordinance #24-05 was not a legislative change subject to referendum pursuant to

SDCL 7-18A-15.1. SCVA appeals the circuit court’s determination that Ordinance

#24-05 was not a legislative decision.

Standard of Review

[¶7.] “After the pleadings are closed but within such time as not to delay the

trial, any party may move for judgment on the pleadings.” SDCL 15-6-12(c).

“Judgment on the pleadings provides an expeditious remedy to test the legal

sufficiency, substance, and form of the pleadings. However, it is only an

appropriate remedy to resolve issues of law when there are no remaining issues of

fact.” Sturzenbecher v. Sioux Cnty. Ranch, LLC, 2025 S.D. 24, ¶ 45, 20 N.W.3d 419,

432 (citation omitted). “A motion for judgment on the pleadings can be granted

‘only when there is no dispute as to any material facts and the moving party is

entitled to judgment as a matter of law.’” Id. (citation omitted). “The Court must

accept as true the facts in the complaint and draw all reasonable inferences in the

favor of the nonmoving party.” Id. (citation omitted). “When considering a motion

for judgment on the pleadings, the court considers ‘the pleadings themselves,

-3- #31091

materials embraced by the pleadings, exhibits attached to the pleadings, and

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Save Centennial Valley Association v. McGruder, Counsel Stack Legal Research, https://law.counselstack.com/opinion/save-centennial-valley-association-v-mcgruder-sd-2026.